Reopening of assessment u/s 147 - reasons to believe - no income...

Reopening of assessment u/s 147 - reasons to believe - no income under the head income from House Property has been offered by the assessee during the year under consideration. This reason is not mentioned in the reasons to believe that the income has escaped assessment by reason of failure on the part of the assessee to disclose fully and truly all material facts. Thus, this reason too cannot be considering as fulfilling the condition precedent to the reopening of assessment beyond the period of four years as per the applicable proviso to Section 147 of the Act - HC

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